EXMO规范性文件

AML政策

The purposes of the EXMO’s Anti-Money Laundering and Counter-Terrorist Financing Policy
and Know Your Customer Policy (hereinafter - the “AML/CFT and KYC Policy”) is to
identify,
prevent and mitigate possible risks of EXMO being involved in illegal activity.

In conformity with international and local regulations, EXMO has implemented effective
internal procedures to prevent money laundering, terrorist financing, drug and human
trafficking,
proliferation of weapons of mass destruction, corruption and bribery and to react
correspondingly in case of any form of suspicious activity from its Users.

Money Laundering can be defined as: 'the conversion or transfer of
property, knowing that such
property is derived from criminal activity, or from an act of participation in such
activity, for the
purposes of concealing or disguising the illicit origin of the property, or assisting
any person who
is involved in the commission of such activity to evade the legal consequences of his
action.'

Terrorist Financing can be defined as: 'the willful provision or
collection, by any means,
directly or indirectly, of funds with the intention that the funds should be used, or in
the
knowledge that they are to be used, in order to carry out terrorist acts.'

All firms must adhere to the Money Laundering, Terrorist Financing and Transfer of Funds
(Information on the Payer) Regulations 2017 (MLRs), and be aware of the guidance set
down by
the Joint Money Laundering Steering Group (JMLSG) which provides guidelines within the
United Kingdom on how firms should conduct Due Diligence on their customers, and the
recommendations from the Financial Action Task Force (FATF), an inter-governmental body
whose purpose is the development and promotion of national and international policies to
combat money laundering and terrorist financing.

Other legislation in relation to AML/CTF are:

The Proceeds of Crime Act (POCA), which covers all crimes and any dealing in criminal
property, and creates investigative powers for law enforcement agencies and criminal
offences in
relation to money laundering, for the criminal, the firm and individual employees.

The Terrorism Act, which details a series of offences related to the involvement in
arrangements
for facilitating, raising or using funds for terrorism purposes.

AML/CFT and KYC Policy includes:

Verification procedure;

Compliance Officer;

Transactions Monitoring;

Risk Assessment.

Verification procedures

Customer due diligence (“CDD”) has become one of the international standards for
preventing
illegal activity. Thus, EXMO has implemented its own verification procedures within the
strict
standards of anti-money laundering and counter-terrorist financing procedures.

The EXMO’s identification procedure requires the User to provide EXMO with reliable,
independent source documents, data or information (for example, a national ID card, an
international passport, a bank statement, a utility bill). For such purposes, EXMO
reserves the
right to collect the User's identification information for the purposes of AML/CFT
and KYC
compliance.

EXMO will take steps to confirm the authenticity of documents and information provided by
Users. All legal methods for double verification of identification information will be
used, and
EXMO reserves the right to investigate the cases of certain Users whose identities have
been
identified as dangerous or suspicious.

EXMO reserves the right to verify the identity of the User on an ongoing basis,
especially when
its identification information has been changed or its activities appear suspicious
(unusual for a
particular User). In addition, EXMO reserves the right to request from the Users current
documents, even if they have been authenticated in the past.

Information about the user's identification will be collected, stored, shared and
protected strictly
in accordance with the EXMO’s Privacy Policy and relevant rules.

After confirming the identity of the user, EXMO may refuse to provide services to the
User if
EXMO’s services are used for the purposes of conducting illegal activities.

Users who intend to use payment cards for the purpose of consuming services must undergo
a
card check in accordance with the instructions available on the EXMO’s website.

Compliance Officer

The Compliance Officer is the person, duly authorized by EXMO, whose duty is to ensure
the
effective implementation and enforcement of the AML/CFT and KYC Policy. It is the
Compliance Officer’s responsibility to supervise all aspects of EXMO’s anti-money
laundering
and counter-terrorist financing procedures, in particular:

collecting Users’ identification information;

establishing and updating internal policies and procedures for the completion,
review,
submission and retention of all reports and records required under the applicable
laws and
regulations;

monitoring transactions and investigating any significant deviations from normal
activity;

implementing a records management system for appropriate storage and retrieval of
documents, files, forms and logs, updating risk assessment regularly, providing law
enforcement with information as required under the applicable laws and regulations.

The Compliance Officer is entitled to interact with law enforcement, which are involved
in
prevention of money laundering, terrorist financing and other illegal activities.

Transactions Monitoring

The Users are known not only by verifying their identity (who they are) but, more
importantly, by analyzing their transactional patterns (what they do).

Daily check of Users on the presence in the recognized “black lists” (e.g. OFAC),
aggregating transfers by multiple data points, placing Users on watch and service
denial
lists, opening cases for investigation where needed, sending internal communications
and
filling out statutory reports, if applicable;

Case and document management.

In connection with the AML/CFT and KYC Policy, EXMO will:

monitor all transactions and it reserves the right to ensure that transactions of
suspicious nature are reported to the proper law enforcement through the Compliance
Officer;

request the User to provide any additional information and documents in case of
suspicious transactions;

suspend or terminate User’s Account when EXMO has a reasonable suspicion that such
User is engaged in illegal activity.

However, the above list is not exhaustive and the Compliance Officer will monitor Users’
transactions on a regular basis in order to define whether such transactions are to be
reported and treated as suspicious or are to be treated as bona fide.

Risk Assessment

EXMO, in line with the international requirements, has adopted a risk-based approach to
combating money laundering and terrorist financing. By adopting a risk-based approach, EXMO
is able to ensure that measures to prevent or mitigate money laundering and terrorist
financing are commensurate to the identified risks.